Requirement to Correct deadline 30 Sept 2018

https://www.gov.uk/guidance/requirement-to-correct-tax-due-on-offshore-assets#part-one-the-legislation-and-its-application

Ok, so this only applies if you actually would OWE HMRC tax on foreign assets, correct?

So having money in an IRA or other similar retirement plan in the USA is not taxable, per tax treaty, until one withdraws the money. So there is no reason to report anything to the HMRC related to it/them as a foreign asset until one actually takes a disbursement - and then the disbursement is the reportable item.
Correct?

https://www.gov.uk/guidance/requirement-to-correct-tax-due-on-offshore-assets#part-one-the-legislation-and-its-application

Ok, so this only applies if you actually would OWE HMRC tax on foreign assets, correct?

So having money in an IRA or other similar retirement plan in the USA is not taxable, per tax treaty, until one withdraws the money. So there is no reason to report anything to the HMRC related to it/them as a foreign asset until one actually takes a disbursement - and then the disbursement is the reportable item.
Correct?

I believe you are correct.  It is foreign income you have to report to HMRC not simply assets that are not producing income. Funds inside an IRA may well pay out interest and dividends but if they are reinvested in the IRA and not withdrawn then they are not taxable or reportable to HMRC.

I have not been taking distributions from my IRA but have been taking distributions from my Roth  IRA which is tax free in both countries. I have been reporting the distributions from the Roth in the comments section only, and why I have not listed that income as taxable. Nowhere on my return do I report the total value of my IRA or Roth, or any other savings.

Any tax treaty is elective. To benefit from the provisions of the US/UK tax treaty one would have to elect to benefit from the treaty each year. To reduce possible HMRC penalties, a full white space disclosure each year is recommended.

And you would "white space" this only for the income, and then note that it is not disbursed but remains in a retirement plan, and is not taxable until disbursed per Article 18.1 of the UK/USA Tax Treaty?

I note in close reading that the RTC legislation is only applicable to income prior to April 2017, so I have no problems there. I still have not heard back on my Self Assessment filed in April to know what I'm actually going to owe for 2017/18. I plan to pay enough to HMRC to at least cover my IRS tax for 2018 and a carryback to potentially cover part of IRS 2017 (1040X) prior to 31 December 2018. That way, I assume, I can do the Foreign Tax Credit and also pay the amounts normally due to HMRC (1/2 of due payment by the end of Jan 2019) - assuming that HMRC does charge me my "worst case" scenario amount.

I have been checking my online Self Assessment account weekly and there does not appear to be any movement on processing my forms. Is that normal? It's been just over four months now since they received the paper forms.

Ray McCann who wrote this piece is currently President of the CIOT. It lays out the ground rules well: https://www.taxation.co.uk/Articles/2015/08/04/333470/discovery-and-all

Ray McCann who wrote this piece is currently President of the CIOT. It lays out the ground rules well: https://www.taxation.co.uk/Articles/2015/08/04/333470/discovery-and-all

Unfortunately that link is subscriber only.

And you would "white space" this only for the income, and then note that it is not disbursed but remains in a retirement plan, and is not taxable until disbursed per Article 18.1 of the UK/USA Tax Treaty?

I still don't see the requirement to report, even in white space, the gain or loss within a defined contribution pension plan such as a 401k or an IRA or Roth until withdrawals are made as withdrawals are the possible taxable events. I never report the unrealized gains in my taxable investments because they are not taxable until shares are sold and gains realized, I also never report the unrealized capital gain in a property until it is sold and the gain realized.

When living in the UK as a USC Roth distributions are tax free in both countries but are declared on both HMRC and IRS returns with an explanation as to why they not taxable. (On the IRS return it is a code on the 1099-R  and on the HMRC return it is recorded in white space).

I don't expect there to be any negatives in reporting reinvested gains within a DC pension plan or IRA or Roth,  I just don't see the requirement.

I am not a subscriber and found it simply via Google. . Paste this words into Google instead of the direct link: The interaction between discovery, time limits and DOTAS

I still don't see the requirement to report, even in white space, the gain or loss within a defined contribution pension plan such as a 401k or an IRA or Roth until withdrawals are made as withdrawals are the possible taxable events. I never report the unrealized gains in my taxable investments because they are not taxable until shares are sold and gains realized, I also never report the unrealized capital gain in a property until it is sold and the gain realized.

When living in the UK as a USC Roth distributions are tax free in both countries but are declared on both HMRC and IRS returns with an explanation as to why they not taxable. (On the IRS return it is a code on the 1099-R  and on the HMRC return it is recorded in white space).

I don't expect there to be any negatives in reporting reinvested gains within a DC pension plan or IRA or Roth,  I just don't see the requirement.

US qualified plans have no special status under UK domestic law. They are simply investment accounts. Unless one elects into the treaty, the income or gains within the plan would be currently UK taxable. If there has been UK tax relief on contributions, the situation is more complex because of the UKs lifetime limit...but this is an unusual circumstance.

US qualified plans have no special status under UK domestic law. They are simply investment accounts. Unless one elects into the treaty, the income or gains within the plan would be currently UK taxable. If there has been UK tax relief on contributions, the situation is more complex because of the UKs lifetime limit...but this is an unusual circumstance.

Thanks for the clarification, that makes sense. For myself I didn’t return to England until well after retiring so it’s nice to know that I have no complications with contributions since I haven’t made any since retiring.

I did that Google search as you suggest and it worked - thanks for that tip!

So, all the money in the 403B and DCP was earned and deposited into the accounts in the USA prior to my emmigrating.
I did not mention it in my "white space".
All said and done for 2017/18 I probably made $1,800 in interest on both accounts, from May 2017 through the end of March 2018. It all remains in the funds.

Do I need to re-do my 2017/18 HMRC form to include this info, and then state it's exempt from UK tax due to the tax treaty? (I still haven't heard anything from my original filing yet.) If so, I assume I should wait until they deal with the original and then amend it later?